Insights

CFTC Issues No-Action Relief for Swap Data Reporting Error Corrections
Derivatives Anne Montminy, Tim Brown, Drew Godsell Risk Management & Compliance, Strategy & AdvisorySummary
Situation Overview: On December 11, 2025, the Commodity Futures Trading Commission (CFTC) issued no-action relief regarding the correction of errors in swap transaction and pricing data submitted to a swap data repository (SDR).
What:…

Patomak Global Partners Named One of the Top Consulting Firms in Fintech by Chambers & Partners
News, News Release Patomak Global PartnersWASHINGTON D.C. – Patomak Global Partners is honored to share that it has been ranked as one of the top fintech consultancies in the United States for the second consecutive year by Chambers and Partners in the Chambers FinTech Guide 2026.
Each…

SEC’s 2026 SBSD and SBSEF Examination Priorities: What Firms Should Expect and How to Prepare
Derivatives Petar Lovric, Anne Montminy Risk Management & Compliance, Strategy & AdvisorySummary
Situation Overview: The Securities and Exchange Commission’s (SEC) Division of Examinations (Division) released its 2026 examination priorities for Security-Based Swap Dealers (SBSDs) and, for the first time, examinations for Security-Based…

SBSD De Minimis Threshold Phase-In: Potential Relief Ahead, but Firms Should Prepare for All Scenarios
Derivatives Pamela Geraghty, Petar Lovric Risk Management & Compliance, Strategy & AdvisorySummary
Situation Overview: The SEC’s temporary de minimis thresholds for security-based swap dealing activity ($8 billion for credit default swaps and $400 million for non-CDS) are scheduled to change following the expiration of the current…

CFTC Reminds Non-U.S. Swap Dealers of Annual Report Requirements in Newly Issued Advisory
Derivatives Anika Horowitz, Sudhir Jain
On December 2, the CFTC reminded non-U.S. swap dealer chief compliance officers of annual reporting requirements.
This Staff Advisory asserts that many non-U.S. swap dealers have been deviating from chief compliance officer annual reporting…

Swap Dealers Face Further Enforcement Orders in 2022
Derivatives Sudhir Jain, Jamila Piracci, Jill Sommers
CFTC and NFA have issued more than 15 enforcement orders against swap dealers in 2022.
Five key pitfalls stand out as a common denominator: failure to report to Swap Data Repositories, failure to provide sufficient disclosures to counterparties,…

Four Take-Aways from CFTC Year-End Enforcement
Derivatives Sudhir Jain, Jamila PiracciIn September 2021, just days prior to its fiscal year end, the Commodity Futures Trading Commission (CFTC) announced enforcement actions against four Swap Dealers, with monetary fines ranging from $750,000 to $1.5 million. Here are four takeaways…

It Is Wiser to Find Out Than Suppose . . . Sometimes
Derivatives Jamila Piracci, Tim TianMark Twain is credited with coining the phrase “it is wiser to find out than suppose” and at times the maxim holds true today, particularly by any regulated community. Earlier this summer, the Commodity Futures Trading Commission (CFTC)…

FinOps Report: Archegos Debacle Prompts Holistic Counterparty Risk Management
Patomak Analysis Patomak Global PartnersJoanna Fields recently spoke with FinOps Report about the events surrounding the Archegos Capital Management implosion and offered good practice recommendations on how broker-dealers can evaluate and reduce their counterparty risk using a holistic management program.

A Customized Compliance Fence Is Worth the Effort and Investment
Patomak Post Joanna FieldsRegulations already exist, but are firms building out compliance programs to navigate them in a way that meets regulatory expectations while also boosting risk monitoring and the bottom-line?

